Privacy Notice

Version 2026-09-13.1

1. Who is responsible for your information

Hotspot Cards is operated by Kyle Pawlaczyk, who is the data controller for personal information processed through this service. For privacy questions or to exercise your data protection rights, contact kyle.pav@midlandsdesignservices.co.uk.

2. Who this service is for

Hotspot Cards is intended for people aged 18 or over. You must confirm that you are at least 18 when registering. The service is not intended to knowingly collect personal information from children.

3. Information we collect

Passwords are not stored in readable form. The service stores a one-way password hash. Private profile fields such as name, address, postcode, telephone number and email address are encrypted at rest.

4. Where we get the information

Most information is provided directly by you when you register or use Hotspot Cards. Game, room, login and activity information is generated through your use of the service. When you verify a postcode, only the postcode entered is sent to the postcode-validation provider so that the service can check whether it is a recognised UK postcode.

5. Why we use your information and our lawful bases

PurposeInformation usedLawful basis
Create and operate your account, authenticate you, provide rooms, games, chat, scores and leaderboards.Account details, room/game activity and relevant technical/session information.Contract — processing is necessary to provide the service you ask to use and to perform the Terms of Use.
Confirm your email address and send password-reset or essential account messages.Name, email address and security tokens.Contract and, where appropriate, legitimate interests in keeping accounts secure and recoverable.
Validate that a submitted postcode is a genuine UK postcode and support registration integrity.Postcode.Legitimate interests in reducing obviously false registrations and maintaining service integrity.
Maintain account records, administer room access, investigate misuse, prevent abuse, protect the service and troubleshoot faults.Account/contact details, activity records, room records, audit/security information.Legitimate interests in operating a secure, reliable and appropriately administered service.
Meet applicable legal obligations or respond to lawful requests.Only information reasonably necessary for the relevant obligation or request.Legal obligation where UK law requires the processing.

We do not treat your acceptance of the Terms of Use or acknowledgement of this Privacy Notice as blanket consent to process your information. If we introduce a separate activity that legally requires consent, we will ask for that consent separately.

6. Registration information and address checks

Your postcode is checked against the free Postcodes.io service. The postcode check confirms that the postcode is recognised; it does not prove that you live at the address you enter. Your full street address is entered manually and is not sent to Postcodes.io by Hotspot Cards.

7. Who can see your information

Other users who can access the same room can see your username and information that is part of normal room/game interaction, including the room's retained chat messages, game status and leaderboard results. Chat messages may therefore remain visible to room members after you leave the table, until they fall outside the room's 500-message retention limit or the room is permanently deleted. Other users are not given access to your private registration profile such as your name, postal address, telephone number or email address.

The master administrator can access private registration information where necessary to administer accounts and the service. Passwords cannot be viewed by the administrator because only password hashes are stored.

8. Service providers and sharing

We do not sell your personal information and we do not use your registration information for third-party advertising.

9. International transfers

Some suppliers, including Microsoft, may process information outside the UK. Where personal information is transferred internationally, the transfer must be covered by an applicable UK adequacy regulation or appropriate safeguards recognised under UK data protection law, such as contractual transfer safeguards. Supplier arrangements may change over time, so current transfer information can be requested from the administrator.

10. How long we keep information

We will not deliberately keep identifiable personal information indefinitely where there is no continuing need for it.

11. Security

Hotspot Cards uses measures designed to protect personal information, including encrypted private profile fields, one-way password hashing, HTTPS for the public service, access controls, CSRF protection, restricted administrator functions and server-side storage of encryption credentials/secrets. No online service can guarantee absolute security, but access is limited according to the functions a user or administrator needs.

12. Cookies and local device storage

Hotspot Cards uses a first-party session cookie that is necessary for sign-in, maintaining your authenticated session and protecting requests against misuse. It is used to provide the service you request rather than for advertising or behavioural tracking. Hotspot Cards does not currently use analytics or advertising cookies.

13. Automated decision-making

Hotspot Cards does not use solely automated decision-making or profiling that produces legal or similarly significant effects. Automated game rules, inactivity removal, postcode validation and security checks are functional parts of the service and do not make legal or similarly significant decisions about you.

14. Your data protection rights

Depending on the purpose and lawful basis, you may have rights to:

To exercise a right, email kyle.pav@midlandsdesignservices.co.uk. We may need to verify your identity before responding. Data-protection requests are normally answered within the timeframe required by UK law.

15. Complaints

Please contact the administrator first if you have a privacy concern so that it can be investigated. You also have the right to complain to the UK Information Commissioner's Office (ICO). Information about making a complaint is available at ico.org.uk/make-a-complaint.

16. Is providing the information compulsory?

The fields marked as required during registration are required to create a Hotspot Cards account under the current service design. If you do not provide them, an account cannot be created. You are not under a statutory obligation to register for or use Hotspot Cards.

17. Changes to this notice

This notice may be updated if the service, suppliers, legal requirements or processing activities change. Material changes will be brought to registered users' attention where appropriate, and the version/date shown above will be updated.